SOP 2.

11: Ergonomics
Household
Hazardous
Waste

Contents
1. Introduction..............................................................................1
2. Regulatory and contractual requirements.................................1
3. Safety and health requirements...............................................1
4. Worksite analysis......................................................................2
5. Hazard control recommendation plan.......................................2
Attachment A: Ergonomic-related Hazards and Controls..................3

1. Introduction
This Household Hazardous Waste (HHW) Facility shall implement an ergonomics program to prevent
temporary or permanent staff injury. This can occur when incorrect or repetitive body motions are
performed during normal operations. This Facility shall establish a process for developing task specific
guidelines to assist in recognizing and controlling potential ergonomic hazards.

2. Regulatory and contractual requirements

Ergonomic requirements are established in OSHA 29 CFR General Duty Clause, Section 5(a)(1). For
information on ergonomics see www.doer.state.mn.us/ei-safih/ergo.htm.

3. Safety and health requirements

3.1 The person designated to ensure that proper ergonomic techniques are implemented for this HHW
Program is the Facility Manager. This person shall:
1.recognize the potential of ergonomic stressors that could adversely impact Facility staff health
and safety.
2.implement corrective actions to reduce the duration, frequency, and severity of exposure to
ergonomic stressors (establish controls such as addressing proper work-related techniques or
provide on the job training).
3.ensure staff reporting ergonomic-related symptoms are referred to the nearest medical facility
for surveillance or treatment,
4.perform worksite analysis or surveys to validate whether efforts to eliminate or reduce
ergonomic risk factors have been effective to the extent feasible,

3.2 Each staff handling HHW shall participate in safety and health trainings (initial and annual) offered
through the State, or may attend equivalent training courses.

Ergonomics 2.11

3.3 All new staff shall receive additional job specific training in accordance with this Facilitys written
training program; see SOP 1.4 HHW Training Requirements.

4. Worksite analysis
Be aware of common contributing ergonomic-related problems or conditions at other HHW facilities as
they may also be a concern for this Program (www.osha.gov/SLTC/ergonomics/common_contrib.html).
Ergonomic worksite analysis shall emphasize an evaluation of work place practice controls and
operational tasks. These may include the following questions:
Did this Facility strive to keep the workplace free of hazards?
Do hazards exist which may cause death or serious physical harm?
Have potential hazards been recognized?
Is there a feasible means of abatement for those hazards?
Is staff reporting ergonomic-related symptoms?
Does staff ensure proper ergonomic improvements are implemented in their specific work
area(s)?
Does staff consistently follow suggested ergonomic improvements?

4.1 Review injury and illness records

If access is available, the designated Program staff person responsible for maintaining health and
safety records shall review staff injury and illness records for potential ergonomic-related problems.
These records may include:

Workers compensation claims

Absentee and turnover records

Group health insurance records

Records of staff complaints or grievances

First aid logs

First report of injury/OSHA 300 log

4.2 Identify potential musculoskeletal disorders

After review of the above information sources, identify entries that may indicate the presence of
musculoskeletal disorders (MSDs). While there is no single diagnosis for MSDs, the conditions
identified below are commonly included in the range of conditions that potentially constitute an
MSD.

tendonitis

deQuervains disease

tenosynovitis

ganglion cyst

epicondylitis

thoracic outlet syndrome

carpal tunnel syndrome

sprains, strains, or tears

bursitis

pain

4.3 Categorize hazards

Once recognized, categorize the MSD cases as related to work tasks to pinpoint where patterns or
trends exist.

4.4 Seek staff input

Request information from staff about the existence of ergonomic problems related to particular jobs
or tasks. This will be accomplished by:

speaking with staff

conducting symptom surveys

providing staff with questionnaires

ensuring effective housekeeping to minimize the potential for slips, trips, and falls

5. Hazard control recommendation plan

If ergonomic hazards are identified, draft a written hazard control plan and update it as needed, including:
descriptions of specific jobs
details of all potential hazards associated with the job task; see Attachment A of this SOP
possible approaches to controlling the hazard
descriptions highlighting the effectiveness of each control approach

Attachment A

Ergonomic-related Hazards and Controls

The following is a list of HHW tasks, potential ergonomic hazards, and possible control methods. Note: not all
hazards have been identified. Some solutions may work for multiple situations, but may not always work for
each task or individual.

Receiving and unloading containers from vehicles

Issues
Lifting,
repetition,
twisting, or
carrying
waste loads

Prevention

Slide waste load toward edge of

tailgate/trunk, closer to body

Rotate staff to reduce time spent lifting

Request assistance for large or

awkward loads

Do not twist with the load, move your

Use a hook to slide containers toward

the back of trunks or truck beds

Reduce the size of the load

Use a two-wheel cart

Use back belts

Use proper lifting technique

feet

Have cart located near the vehicle to

reduce carrying distance

Utilize top cart shelf to avoid

physically lowering the load

Take frequent breaks

Have the participant unload their own

vehicle

Ensure adequate numbers of staff are

available

Sorting
Issues
Standing,
trips, twisting,
or bending

Prevention

Elevate receiving container

Rotate staff and tasks

Anti-fatigue, anti-static, or rubber mats

Smaller, shorter/lower gaylord height

Minimize twisting or sharp movements

Hook in gaylord to reach containers

Adjust table heights

Gaylords with sides that open

Platforms or stools

Roller or conveyer system

Shoe inserts

Wrist support

Have table and cart at the same height

Take adequate breaks

Restrict time on each task

Hook in gaylord to reach containers

Transferring containers to gaylords or lab packing

Issues
Bending,
lifting,
lowering
waste loads,
or contact
stress

Prevention

Purchase or create gaylords that open

on one side

Hoist or scissor platform (spring) inside

the gaylord

Lifting/transferring large objects and car batteries to bins or gaylords

Issues
Lifting loads,
repetition,
twisting

Prevention

Training on proper lifting techniques

Elevating battery storage bins

Back belts

Have the participant unload their own

items
Use more people to assist

Forklift to move pallet closer to

storage bins (vs. transferring one battery
at a time)
Pneumatic lift or platform

Lifting 5-gallon containers

Issues
Lifting,
repetition,
twisting, or
pouring waste

Prevention

Proper lifting techniques (correct

posture, wrist and arm placement)

Transfer waste into smaller

containers prior to final bulking procedure

Proper lifting device (hoist, pulley,

forklift, platform)

Allow someone else to lift the

container Auto-siphons

Ensure an adequate number of staff is

available to assist

Have gradual work heights to lift from

floor height

Tilt can to empty (vs. lift)

Back belts

Low profile funnel

Ensure working surfaces are at the

same height as the container receiving
waste

Limit number of cans to process

(open only newer cans for reuse)

Opening and bulking paint cans

Issues
Repetition,
awkward wrist
angle, lifting,
bending,
stirring, and
long periods
of standing

Prevention

Avoid screwdrivers to open containers

Paint can opener, hatchet or vice grip for

opening containers

Wrist supports
Loosen lid with hammer

Switch hands to reduce fatigue

Re-engineer design of can openers

Reduce work time

Ship un-bulked in gaylords or lab

packs to avoid opening

Rotate the job task and shifts

Hire additional staff

Can crusher, puncturing device or

pneumatic opener

Mounted scraper

Crown punch or machine to cut

container tops out

Moving Large Containers or 55-gallon Drums

Issues
Repetition,
lifting,
bending

Prevention

4-wheel cart/or 4-wheel base

Drum-righter tool

Secure the load

Back belts

Forklift with drum grabbers

Move containers on smooth, flat

surfaces vs. gravel

Drum dolly (use two staff to tip)

Change cartridge type from dual to

chemical cartridge with a pre-filter

Use additional staff while moving

containers on ramps

Respirators
Issues
Neck strain

Prevention

Take breaks and limit the amount of use

time